Income Tax : This guide explains the tax exemptions, concessional tax rates, presumptive taxation schemes, and compliance benefits available to...
Income Tax : The guide compiles the principal Income-tax Act provisions applicable to non-residents establishing business in India and resident...
Income Tax : Tax on dividends, interest, royalties and FTS earned by non-residents is governed by the more beneficial rate under the Income-tax...
Income Tax : The applicable withholding tax depends on the Income-tax Act or the relevant DTAA, whichever is more beneficial. Treaty rates diff...
Income Tax : The article explains how India's Place of Effective Management (POEM) rules may treat a foreign company as an Indian tax resident ...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...
Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...
Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...
Income Tax : Appendix-I Declaration of no PE in India Declaration required u/s 9 of Income Tax Act, and for claiming relief under an agreement ...
Income Tax : The Tribunal held that AMP expenditure incurred in India without any agreement or arrangement with the foreign AE cannot be treate...
Income Tax : The Bombay High Court held that royalty refunded by a foreign company to its Indian subsidiary under an Advance Pricing Agreement ...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
Income Tax : The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...
Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....
Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...
Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...
Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...
Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...
Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...
The Agreement provides for relief from double taxation for airline enterprises of India and Maldives by way of exemption of income derived by the enterprise of India from the operation of aircraft in international traffic, from Maldivian tax and vice-versa.
In order to curb the erstwhile lacuna in the language of the Act and to prevent formations of various foreign shell companies, which are eventually controlled and managed from India, the Government of India amended the provision of clause (ii) of sub-section 3 of section 6 of the Act vide Finance Act, 2015 to avoid future revenue losses and prevent tax abuse.
Delhi High Court held In the case of Principal CIT vs. M. Tech India Pvt. Ltd that in cases where the payments are made for purchase of software as a product, the consideration paid cannot be considered to be for use or the right to use the software.
The ITAT Chennai held that payments made by the assessee in the nature of webhosting and marketing expenses to US based service provider could not be taxed as Fees for technology services because there were not transfer of technology involved in render of services such that the services could be continuously used by the Indian company without recourse to the service provider.
Finance Minister Shri Arun Jaitley has emphasized the need for common reporting standards on Automatic Exchange of Information to be implemented globally to prevent international tax evasion and avoidance.
The Finance Act 2015 has introduced a major change to the definition of residential status of companies vide amendment to Section 6(3) of the Income Tax Act, 1961 (‘Act’) which is likely to have significant impact with respect to foreign companies.
To begin with, what constitutes an HNI is really a tricky question? In general parlance, HNIs are understood to be the individuals with ultrahigh net worth with deep pockets having surplus investible funds. As per the Credit Suisse Global Wealth Report, presently India is home to around 1,500 ultra-high net worth individuals with wealth of at least US$ 50 million and 700 who have more than US$ 100 million of assets.
07/08/2015 – The OECD today releases three new reports to help jurisdictions and financial institutions implement the global Standard for automatic exchange of financial account information. Common Reporting Standard Implementation Handbook (the CRS Handbook): this first edition provides practical guidance to assist government officials and financial institutions in the implementation of the Standard. It sets […]
Lump-sum payments are covered under the term royalty. The agreement postulated grant of permission to use or right to use intellectual property rights or knowhow and it is not a case of outright sale.
India and United States Signs Inter Governmental Agreement (IGA) to Implement the Foreign Account Tax Compliance Act (FATCA) to Promote Transparency on Tax Matters Mr. Shaktikanta Das, Revenue Secretary of India and Mr. Richard Verma, U.S. Ambassador to India signed here today , an Inter Governmental Agreement (IGA) to implement the Foreign Account Tax Compliance […]
